UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
February 8, 1983
TO ALL OPERATING REACTOR LICENSEES, APPLICANTS FOR AN OPERATING LICENSE AND
HOLDERS OF CONSTRUCTION PERMITS FOR COMBUSTION ENGINEERING PRESSURIZED WATER
REACTORS
Gentlemen:
SUBJECT: REVIEW OF COMBUSTION ENGINEERING OWNERS' GROUP EMERGENCY
PROCEDURES GUIDELINE PROGRAM (Generic Letter No. 83- 09)
This letter provides preliminary acceptance of the CE Owners' Group (CEOG)
Emergency Procedure Guidelines for implementation in plant specific
emergency procedures and outlines our requirements for additional work in
this area. The staff has identified technical and administrative issues
which require timely resolution. We also require a program to manage future
changes as the need is identified.
Our review has progressed to the point where we conclude that implementation
of the guidelines should provide a greater assurance of operational safety
than presently exists. Therefore, you should proceed with plant-specific
implementation. We anticipate issuing an SER subsequent to our review of the
CEOG formal submittal of CEN-152, "Combustion Engineering Emergency
Procedure Guidelines," dated November 22, 1982. We anticipate that our SER
will find CEN-152 acceptable. Both this conclusion and our conclusion that
you should begin implementation of Emergency Procedure Guidelines into plant
specific procedures are based on the judgment that no further major problems
in the proposed guidelines are expected. Our conclusions are further based
upon the assumption that the results from the NRC/CE Owners' meetings are
reflected in the CEOG CEN-152 submittal. We suggest that the implementation
program contain three elements:
(1) Preparation of plant specific procedures based on the Emergency
Procedure Guidelines referenced above and implementation of these
procedures as outlined in Supplement 1 to NUREG-0737, transmitted
by Generic Letter No. 82-33 dated December 17, 1982.
(2) A program for the preparation of supplements to the generic
guidelines or plant specific guidelines which cover changes, new
equipment, or new knowledge and incorporation of these supplements
into the procedures.
(3) Completion of and improvements to the Emergency Procedure
Guidelines (EPG) or plant specific procedures in the longer term.
8302080295
.
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The prompt implementation of Step 1 will allow the benefits of the
significant improvements you have achieved to be realized soon.
Step 2 refers to a program for guideline or procedure updates which will be
generated as a matter of routine after the implementation. This essentially
is a maintenance function.
Step 3 refers to a program for addressing those aspects of the guidelines
and procedures where additional long term work may be needed, either in your
emergency procedure program or a part of abnormal procedure updates. A
listing and discussion of identified issues will be provided in the staff
SER. It is anticipated that one or more of these areas will be resolved
under TMI action item I.C.9.
Because the Emergency Procedure Guidelines must be dynamic in that changes
must be made to reflect changes in equipment or new knowledge, we expect the
CE Owners' Group or a similar coalition of utilities and vendors to accept
responsibility for continued maintenance of the guidelines. Therefore, we
have requested in the enclosed letter that the CE Owners' Group provide a
description of the program for steps (2) and (3) above.
Sincerely,
Darrell G. Eisenhut, Director
Division of Licensing
Enclosure:
Letter to Mr. Wells
dated
.
ENCLOSURE
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
February 4, 1983
Mr. R. W. Wells
Chairman, CE Owners Group
Box 270
Hartford, CT 06141-0270
Dear Mr. Wells
This letter provides preliminary acceptance of the CE-Owners' Group (CEOG)
Emergency Procedure Guidelines for implementation in plant specific
emergency procedures and outlines our requirements for additional work in
this area. The staff has identified technical and administrative issues
which require timely resolution. We also require a program to manage future
changes as the need is identified.
Our review to date has been primarily based on draft submittals of the CEOG
Emergency procedure Guidelines supplemented with extensive contact between
the staff and CEOG representatives. The current review relied on the
following sources of information:
(1) The draft report "Combustion Engineering Emergency Procedure
Guidelines," CEN-152 Revision 01, August, 1982
(2) Response to our questions titled "Resolutions to Procedures and Test
Review Branch Questions and Comments on C-E Emergency Procedure
Guidelines, June 29, 1982" (no date)
(3) Response to our questions titled "Resolutions to Warren C. Lyon's
Questions and Comments on C-E Emergency Procedure Guidelines, June 23,
24, 29" (no date)
(4) Results from Meetings between C-E (and in some cases with C-E Owner's
Group representatives) and NRC between 1979 and 1982.
Our review has progressed to the point where we conclude that implementation
of the guidelines should provide a greater assurance of operational safety
than presently exists. The CE owners should proceed with plant-specific
implementation. We anticipate issuing an SER subsequent to our review of
your formal submittal of CEN-152, "Combustion Engineering Emergency
Procedure Guidelines" dated November 22, 1982. We anticipate that our SER
will find CEN-152 acceptable. Both this conclusion and our conclusion that
you should begin implementation of Emergency Procedure Guidelines into plant
specific procedures are based on the judgment that no further major
.
Mr. R. W. Wells - 2 - February 4, 1983
problems in the proposed guidelines are expected. Our conclusions are
further based upon the assumption that the results from the NRC/CE Owners
meetings are reflected in your CEN-152 submittal. The enclosure presents our
thoughts on the implementation phase.
Sincerely,
Darrell G. Eisenhut, Director
Division of Licensing
Enclosure:
Implementation Program
cc: w/enclosure
CE Licensees
CE Applicants
CE
J. Barrow, CE Owners Group
G. Bishoff, CE
V. Callahan, CE
R. Pearce, CE
.
IMPLEMENTATION PROGRAM
We suggest that the implementation program contain three elements:
(1) Preparation of plant specific procedures based on the Emergency
Procedure Guidelines referenced above and implementation of these
procedures.
(2) A program for the preparation of supplements to the generic
guidelines or plant specific guidelines which cover changes, new
equipment, or new knowledge and incorporation of these supplements
into the procedures.
(3) Completion of and improvements to the Emergency Procedure
Guidelines (EPG) or plant specific procedures in the longer term.
The prompt implementation of Step 1 will allow the benefits of the
significant improvements you have achieved to be realized soon.
Step 2 refers to a program for guideline or procedure updates which will be
generated as a matter of routine after the implementation. This essentially
is a maintenance function.
Step 3 refers to a program for addressing those aspects of the guidelines
and procedures where additional long term work may be needed, either in your
emergency procedure program or a part of abnormal procedure updates. A
listing and discussion of identified issues will be provided in the staff
SER. It is anticipated that one or more of these areas will be resolved
under TMI, action item I.C.9.
A. Generic items, ATWS rulemaking, SPDS designs, RCS vent
installations, and ICC instrumentation. Unresolved Safety Issues
may also enter this list.
B. Technical items such as the following:
a. EPG coverage extention into electrical power supply
availability so that plant behavior under such events as
station blackout is covered.
b. Management of accidents such as multiple ruptured steam
generator tubes from the viewpoint of radioactivity release
and a more complete procedure for SGTR.
c. Containment coverage.
d. Additional consideration for condensate management, such as
the coverage of alternate sources of water.
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C. Potential behavior under conditions where physical phenomena may
differ from those discussed in the EPG needs evaluation and
coverage. Typical are the following:
a. Hydraulic-instabilities which may introduce unusual
instrument readings which could mislead an operator to take
an unwarranted action.
b. Degraded core conditions and guidance for operator response
under these conditions.
D. Several items are plant specific; but general guidance is
applicable. These include:
a. Differences between plants with and without PORVs and
differences in PORV sizing and possible instruction a
perturbations.
b. The influence of sensor location, such as positioning of hot
leg temperature determination devices, and feedback into
operator instructions.
We request that you describe your program for Items (2) and (3), above, of
the implementation program.